Willis Chung

Sclera Digital, Inc. 1100 Wilshire Blvd., #1803 Los Angeles, CA 90017 ( 818 ) 835

- 3128 willisxchung@gmail.com

**Petition for Exemption Federal Aviation Administration**  Re: Unmanned Aircraft Sy stem use in NAS for compensation
Petitioner, Sclera Digital, Inc. (“Sclera”) , hereb y petitions the Federal Aviation Administration ( “ FAA ” ) for an exemption from Part 21; §§ 45.23(b); 61.113(a) and (b); 91.7(a); 91.9(b)(2); 91.103; 91.109; 91 .119; 91.121; 91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). The proposed exemption, if granted, would allow operation of unmanned aircraft s ys tems (UAS) for the purpose of closed

- set filming for the motion picture and television industry

. The terms and conditions of Grant of Exemption No. 11062 ( Petition of Astraeus Aerial, Regulatory

Docket No. FAA

- 2014

- 0352 ) are hereby incorporated b y this reference as if ful ly set for herein with the exception of the mandatory Class 3 medical certificate. Petitioner hereb y proposes the following terms and conditions for the grant of the exemption requested herein: The UAS proposed b y the petitioner , the **Inspire 1** is an unmanned four

- rotor, four

- motor “quadcopter” manufactured by DJI . The UA S is under 4 5 pounds , wi ll be flown at all times under 3 00 feet AGL as measured b y the UA S’ on - board GPS sy stem , will be kept within line of sight of the Pilot in Command (“PIC”) , will have a separate safety Visual O bserver (“VO”) at all times in communication with and within 5 feet of the PI C, will be flown at all times at speeds of 40 miles per hour or less , will be flown at all times during daylight hours , alway s using Visual Flight Rules (“VFR”) and within visual line of sight (“VLOS”) , and never using first person view by the PI C . The PIC will be able to use human vision unaided by any device other than corrective lenses as specified by a current state

- issued driver ’ s license . The PI C will provide the local Flight Standards District Office (“FSDO”) with notice of all of flight operations no less than 72 hours in advance of an y intended flight

. Each PI C will have over 400 hours of logged flight experience in the same UAS ty pe or model, including 10 take offs and landings within the prior 30 day s . The PIC will conduct a f ull and complete inspection of aircraft prior to the initial takeoff of each flight. Public BenefitRegular helicopters are, except as provided in Section 91.119, not allowed to fly less than 500 feet AGL. UAS on the other hand are best when flown between 50 and 300 feet AGL and in fact the best video quality is 50 to 100 feet. A large manned helicopter could also cause very serious damage to persons or property on the ground and even to pilots and passengers inside a manned helicopter. A UAS weighing in at approximately six pounds would not be nearl y as hazardous. Additionally , a regular helicopter is normally larger than a standard automobile whereas th e UAS is smaller than a basketball. It is substantially safer for the public to have a UAS accomplish the job of aerial photograph y than a manned helicopter just based on size alone. In addition, the UAS can be operated for substantially less costs than a regular manned helicopter. The public is significantl y served b y reducing the cost of videograph y via UAS aircraft. Proposed Operational Parameters The PI C will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, ins pection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements will be established and identified in the operator’s manual. At a minimum, the following w ill be included in the operator’s manual: 1. Actuators / Servos 2. Transmission (single rotor) 3. Powerplant (motors) 4. Propellers 5. Electronic speed controller 6. Batteries 7. Mechanical dy

namic components (single rotor) 8. Remote command and control 9. Ground control station (if used) 10. Any other components as determined by the operator Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation o f the UAS, the aircraft will be prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, will be included in the preflight inspection. A ll maintenance and alterations will be properl y documented in the aircraft records. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics ( e.g. replacement of a flight critical component) will under go a functional test flight in accordance with the operator’s manual. The PI C who conducts the functional test flight will make an entry

in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft re cord entry must be added to the operator’s manual.Prior to operations conducted for the purpose of motion picture filming (or similar

operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of five hours as a UAS pilot operating the make and model o f UAS to be utilized for operations under the exemption and three take

- offs and three landings in the preceding 90 day s. Training, proficiency , experience

- building, and take

- off and landing currency flights can be conducted under this grant of exemption to accomplish the required flight time and 90 day currency . During training, proficiency , experience

- building, and take

- off and landing currency flights all persons not essential for flight operations are considered non

- participants, and the PI C must operate the UA with appropriate distance from non

- participants in accordance with 14 CFR § 91.119. Prior to any

flight operations authorized by this grant of exemption, the PIC and VO must have successfull y completed a qualification process, as outlined in the operator’s manual. As this is a requirement stipulated by the operator, the test must be developed and implemented by a qualified person designated at the sole discretion of the operator. A record of completion of this qualification process must be documented and made available to the Administrator of the FAA (the “Administrator”) upon request. Prior to operations conducted for the purpose of motion picture filming (or similar operations), a flight demonstration, administered by an operator

- approved and qualified pilot must be successfull y completed and documented. This documentation must be available for review upon request b y the Administrator. Because the knowledge and airmanship test qualifications have been developed b y the operator, and there are n o established practical test standards that support a jurisdictional FAA FSDO evaluation and approval of company designated examiners, the petitioner will conduct these tests in accordance with the operator’s manual. The UAS will not be operated directl y over an y person, except authorized and consenting production personnel, below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergency

. Regarding the distance from participating persons, the operat or’s manual has safety mitigations for authorized and consenting production personnel. At all times, those persons must be essential to the closed

- set film operations. Because these procedures are specific to participating persons, no further FSDO or Aviation Safety Inspector ( “ ASI ” ) approval is necessary for reductions to the distances specified in the petitioner’s manuals. This is consistent with the manned aircraft procedures described in FAA Order 8900.1, V olume 3, C hapter 8, S ection 1 Issue a Certifica te of W aiver for Motion Picture and Television Filming (the “Order”)

. Regarding distance from non

- participating persons, the operator will ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and necessary for the filming production. This provision may be reduced to no less than 200 feet if it would not adversel y affect safety and the Administrator has approved it. For example, an equivalent level of safety may be determined b y an aviation safety inspector’s evaluation of the filming production area to note terrain features, obstructions, buildings, safety barriers, etc. Suchbarriers may protect non

- participating persons ( e.g. observers, the public, news media) from debris in the event of an accident. This i s also consistent with the Order

. If the UAS loses communications or loses its GPS signal, the UA S must return to a pre

determined location within the security perimeter and land or be recovered in accordance with the operator’s manual. The proposed UAS , the DJI Inspire 1, is designed to increase altitude 20 meters or 60 feet upon loss of signal between the ground controller held b y the pilot and the aircraft itself. Upon reaching the higher altitude (a safety feature to avoid people, trees and buildings), the UAS will retur n to its original take

- off point of origin and slowly land. Itis critically important for the pilot to calibrate the aircraft prior to its flight. The calibration procedure sets the compass and lets the aircrafts onboard computer know where it is located on E arth. The UAS also has a F ly trex black box sy stem installed which tracks every flight so if a loss of link to the aircraft from the controller ever occurs, then the pilot can follow and retrieve the UAS when it lands. Additional details concerning los t

- link failsafes can be found in the Operator’s Manual. The PI C will abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator’s manual. Each UAS operation must be completed within 30 minutes flight time or wi th 25% battery power remaining, whichever occurs first. The PI C will request a Notice to Airmen (“NOTAM”) not more than 72 and not less than 48 hours prior to the operation. The operator will develop procedures to document and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS. These procedures will be added to the operator’s manual. Each UAS operated under this exemption will comply with all manufacturer Safety Bulletins. The operator must develop UAS technician qualification criteria. These criteria must be added to the operator’s manual. The preflight inspection section in the operator’s manual must be amended to include the following requirement: The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant prefli ght inspection sections of the operator’s manual. Before conducting operations, the radio frequency spectrum used for operation and control of the UA S must comply with the Federal Communications Commission ( “ FCC ” ) or other appropriate government oversight agency requirements.At least three days before scheduled filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed filming. The 3

- day notification may

be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights b. Name and phone number of the operator for the UAS filming production conducted under this grant of exemption c. Name and phone number of the person responsible for the on

- scene operation of the UAS d. Make, model, and serial or N

- number of UAS to be used e. Name and certificate number of UAS PI Cs involved in the filming production event f. A statement th at the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request. g. Signature of exemption

- holder or r epresentative The documents required under 14 CFR § 91.9 and § 91.203 will be available to the PI C at the ground control station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforce ment official upon request. The UA S will remain clear and yi eld the right of way to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, e tc.). UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions ( “ VMC ” ). Flights under special visual flight rules ( “ SVFR” ) are not authorized. The UAS will be operated by the PIC from any

moving device or vehicle. The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PI C. The UA will not operate in C lass B, C, or D airspace without written approval from the FAA. The UA will not operate within 5 nautical miles of the geographic center of a non

- towered airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required b y the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.Any 1) incident , 2) accident, or 3) flight operation that transgresses the lateral or vertical boundaries of the operational area as defined b y the applicable COA must be reported to the FAA UAS Integration Office (AFS

- 80) within 24 hours. Such a ccidents must be reported to the National Transportation Safety Board ( “NTSB ” ) per instructions contained on the NTSB Web site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or transgression is reviewed b y AFS

- 80 and authorization to re sume operations is provided. Unless otherwise specified in this grant of exemption, the UAS, PI C, and operator must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. The Federal Aviation Administration by and through its authorized representative is requested to approve this petition based on the above terms and conditions for a certificate of authority and certificate of exemption to operate within the above parameters for compensation or hire within th e United States National Air Space. Respectfully

submitted:
Willis Chung